Risk Assessment Service for Legionella

Our approach for Legionella risk reduction was borne in the United Kingdom over 25 years ago making Nalco one of the first companies in the world to provide risk reduction services specifically for Legionella. Our practices are based on many industry best practices and guidelines from around the world. Our approach has mirrored the emerging approach for Legionella risk reduction that models “Hazard Analysis and Critical Control Point (HACCP)” plans established in 1996 by the food industry in the United States to reduce transmission of infectious organisms from food to humans.

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The foundation of our service portfolio over the past 20 years is a Hazard Analysis and Critical Control Point Plan (HACCP Plan). Hazard analysis is the first essential step in reducing risk at your site. This in-depth system review and risk assessment goes beyond traditional operational performance factors. It addresses each site and system in terms of a comprehensive risk model for pathogenic microorganism proliferation, aerosol dissemination, and identification of population susceptibility. A HACCP plan provides a comprehensive document that assesses overall site risk as well as individual process unit risk or critical control points, and then provides action plans that serve as the framework for a site-specific and on-going risk management program.

The HACCP Plan is a working tool, designed for regular review to document site changes. The approach was designed in accordance with current recommended practices and guidelines on Legionella control from the Occupational Safety and Health Administration (OSHA); the Centers for Disease Control and Prevention (CDC); the Cooling Technology Institute (CTI); the American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE), and the Health and Safety Commission (HSC) in the UK to name a few.

The HACCP Model

Principle 1 – Hazard Analysis This is an essential first step to assess the potential hazards and conditions associated with the building water system under consideration to decide which are significant and must be addressed in the HACCP plan.

Principle 2 – CCP Identification
Critical Control Points (CPP) are points at which control can be applied and is essential to prevent or eliminate a safety hazard or reduce it to an acceptable level to prevent it from harming people.

Principle 3 – CCP Critical Limits
Maximum and/or minimum limits are established per CCP to prevent, eliminate or reduce to an acceptable level the occurrence of a hazard.

Principle 4 – CCP Monitoring
A planned sequence of observations or measurements to assess whether a CCP is under control and to produce an accurate record for future use in verification.

Principle 5 – Corrective Action
A procedure that defines the actions necessary to correct the conditions at a CCP when test results occur outside of the critical limits.

Principle 6 – Verification Procedures
Verification procedures, other than monitoring, are followed to ensure the HACCP plan is working and that the system is operating according to the plan.

Principle 7 – Documentation & Records A written HACCP plan is maintained and recordkeeping is defined and followed.

The HACCP Plan

A complete written HACCP Plan is produced with the following six elements:
1. Members of the HACCP Team
2. Process Flow Diagrams for the water systems with CPP steps identified
3. Hazard Analysis Summaries to outline water process steps, potential hazards, risk potential or significance with a statement of basis, and current or recommend hazard control.
4. Monitoring schedules are established to document each CCP, the frequency with which each CCP is monitored, and the time frame within which corrective actions shall be taken when critical limits are exceeded.
5. Validation procedures are established that include the scientific evidence used to validate the selection of each CCP and each critical limit selected by the HACCP Team. The selection of critical limits shall comply with local guidance or regulations.
6. Verification schedules are defined that list all verification activities and the frequency with which they will be performed.

Nalco Code of Practice

Nalco’s approach to Legionella risk reduction is based on global best practices and our 75 plus years of experience in the water treatment business. Our services are provided by a dedicated EHS team of experts who are specifically trained in risk management and control of Legionella. Our mission is to reduce health risks due to pathogens.

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